Substantive and Enforcement Jurisdiction in a Post-Wayfair World

90 State Tax Notes 4, 2018

17 Pages Posted: 4 Apr 2019 Last revised: 12 Apr 2019

See all articles by Walter Hellerstein

Walter Hellerstein

University of Georgia School of Law

Andrew D. Appleby

Stetson University College of Law

Date Written: October 22, 2018

Abstract

This article examines the Wayfair case through the lens of substantive and enforcement jurisdiction and focuses on the question of whether there is a constitutionally required relationship between the nexus of the person that the state seeks to enlist as the tax collector and the underlying activity that the state is taxing.

Keywords: State and Local Tax, Wayfair, Commerce Clause, Nexus, Economic Presence

Suggested Citation

Hellerstein, Walter and Appleby, Andrew D., Substantive and Enforcement Jurisdiction in a Post-Wayfair World (October 22, 2018). 90 State Tax Notes 4, 2018, Available at SSRN: https://ssrn.com/abstract=3338106 or http://dx.doi.org/10.2139/ssrn.3338106

Walter Hellerstein

University of Georgia School of Law ( email )

209 Hirsch Hall
Athens, GA 30602
(706) 542-5175 (Phone)
(706) 542-5556 (Fax)

Andrew D. Appleby (Contact Author)

Stetson University College of Law ( email )

1401 61st Street South
Gulfport, FL 33707
United States
727.562.7327 (Phone)

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